In its annual ‘State of Crypto Travel Rule: 2025 Report’, Notabene surveyed data from 91 Virtual Asset Service Providers (VASPs) and 10 regulatory bodies, with its findings indicating that all companies plan to become Travel Rule compliant by the end of 2025. Additionally, the report underlines that approximately nine in ten are expected to meet requirements in the first half of the year, in turn suggesting a broad move toward regulatory compliance.
The Travel Rule requires financial institutions to share specific information about their customers when transferring funds over a certain amount to another entity. Custodian crypto exchanges are mandated to fulfil this regulatory demand.
Currently, compliance is linked to reaching certain counterparties, and since 2024, VASPs have started to be more proactive in their counterparty requirements. Notabene’s report discovered a 431% year-over-year increase in VASPs blocking withdrawals until beneficiary details are confirmed, scaling from 2.9% in 2024 to 15.4% now. At the same time, 19.8% of VASPs return deposits if the originator does not offer the necessary Travel Rule information.
Furthermore, before the EU Transfer of Funds Regulation (TFR) was instituted, more specifically before 30 December 2024, the Notabene network witnessed a substantial increase in activity from EU-based companies. There was a 200 times increase in transaction volumes originating from EU crypto asset service providers, compared to an eight times increase in non-EU-originated volume during the same period. Notabene mentioned that, even if 71% of EU crypto asset service providers did not meet the deadline, the majority of them are working on catching up, with one-third of them implementing processes to identify and report repeat non-compliant counterparties to regulations.
Commenting on the release, representatives from Notabene emphasised that the report’s findings demonstrate that compliance is neither an impending requirement nor a regulatory checkbox, it is a gatekeeper for business. Companies that cannot meet these demands can be excluded from transactions while also losing counterparties and decreasing their volumes.
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